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Other cases that caught our eye: 14 October 2022

PAYE liabilities after selling business: In S Siva v HMRC [2022] UKFTT 344 (TC) (20 September 2022) is a rather unfortunate case where something went wrong and the taxpayer didn’t fix it properly. A business was sold to an employee but the agents (who acted for both the old and new owners) continued to use the existing PAYE reference for at least 12 months before a new reference was obtained. It is not clear exactly what happened but the upshot was that HMRC pursued the old owner for PAYE liabilities return on the old PAYE number. There may have been some double counting but again details are sketchy. The taxpayer appealed to the tribunal to ‘sort matters out’. Unfortunately for her the tribunal judge was unable to do this. She pointed out that her powers were limited to those set out in law. The taxpayer had made PAYE submissions...

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